Jamison v. Cavada

Background

The court considered Defendant’s motion for reconsideration of the portion of its December 5, 2019 memorandum order that had denied summary judgment on Plaintiff’s denial-of-the-right-to-a-fair-trial claim. Defendant also asked the court to clarify the scope of Plaintiff’s April 1, 2014 false-arrest claim. In opposition, Plaintiff asked the court to reconsider its earlier dismissal of his malicious-prosecution claim.

Fair-Trial Claim

The court explained that reconsideration is an extraordinary remedy generally available only when there is an intervening change in controlling law, new evidence, or a need to correct clear error or prevent manifest injustice. Defendant relied on McDonough v. Smith, which the court treated as a change in controlling authority.

The court held that McDonough required dismissal of Plaintiff’s fabricated-evidence claim under 42 U.S.C. § 1983 unless the underlying criminal proceedings ended in Plaintiff’s favor. The court had previously determined that the criminal case’s dismissal on speedy-trial grounds did not affirmatively indicate Plaintiff’s innocence. Because Plaintiff therefore could not show favorable termination, the court granted Defendant’s motion for reconsideration and, upon reconsideration, granted summary judgment on Plaintiff’s denial-of-the-right-to-a-fair-trial claim.

False-Arrest Claim

The court found that Defendant had presented evidence, not genuinely disputed by Plaintiff, that Plaintiff had an outstanding arrest warrant when he was arrested on April 1, 2014. Once Defendant discovered the warrant, he had the right to arrest Plaintiff. The court therefore clarified that Plaintiff could recover damages for the false-arrest claim only for conduct occurring before Defendant discovered the outstanding warrant. The court did not state that it dismissed the false-arrest claim altogether.

Plaintiff’s Reconsideration Request

The court denied Plaintiff’s request to reconsider dismissal of his malicious-prosecution claim. It found that the request did not comply with the requirements for motion papers and, in any event, was filed more than two months after the earlier decision, beyond the 14-day deadline for reconsideration motions. Plaintiff had not explained the delay.

Other Case Status

The case remained referred to Magistrate Judge Aaron for general pretrial management. The parties were directed to contact Judge Aaron’s chambers to schedule a settlement conference. The memorandum order resolved docket entry number 80.